1.44

Object

Representation ID: 8158

Received: 03/09/2021

Respondent: Mr Ross Thomson

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
4. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
5. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
6. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
d. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.44 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8197

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8256

Received: 03/09/2021

Respondent: Mr Daniel Francis

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 8300

Received: 03/09/2021

Respondent: Miss Erin Francis

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.44 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8342

Received: 03/09/2021

Respondent: Mrs K Francis

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These are highlighted grey in my table and include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. [Question for the Planners: Is this reasonable or sufficient?]
3. In the favoured options 2a to 2d, I believe that BBC have failed to properly consider the true impact of new settlements (incl. Dennybrook) on:
a. 6. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. 8. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. 9. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council happily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 8446

Received: 03/09/2021

Respondent: Mr Theodore Cassell

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
4. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
5. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
6. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
d. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

1.44 100 word summary

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Support

Representation ID: 8487

Received: 27/09/2021

Respondent: Gladman Developments Ltd

In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to Sustainability Appraisal (SA). Incorporating the requirements  of  the  Environmental  Assessment  of  Plans  and  Programmes  Regulations  2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable alternatives.
Gladman note that the Draft Plan consultation is accompanied by a Sustainability Appraisal dated June 2021. Bedford Borough Council (BBC) should ensure that the results of the SA process clearly justify its policy choices. In meeting the development needs of the area, it should  be  clear  from  the  results  of  the  assessment  why  some  policy  options  have  been  progressed, and others have been rejected. Undertaking a comparative and equal assessment  of  each  reasonable  alternative,  the  Borough  Plan  Review’s  decision‐making  and scoring should be robust, justified and transparent.
It is noted from the Draft Sustainability Appraisal  Report (July 2021), that more detailed  location options for growth will be considered in the final Sustainability Appraisal Report which will be prepared as the local plan is finalised. Through the sustainability appraisal process, careful consideration should be given to the ability of sites of varying size, location and  nature  to  contribute  towards  sustainably  meeting  future  housing  needs  in  full.   The  wider strategic context of the area as a location for economic growth and change must also be  a  key  factor  in  identifying  a  sustainable  growth  strategy  for  the  borough  through  to  2040.

Object

Representation ID: 8543

Received: 03/09/2021

Respondent: Mrs Claire francis

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 8568

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

APPENDIX 6 OF ATTACHMENT CONTAINS REVIEW OF DRAFT SA

Object

Representation ID: 8615

Received: 13/09/2021

Respondent: Mr Henry Zwetsloot

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
4. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
5. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
6. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
d. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 8682

Received: 13/09/2021

Respondent: Mr J Francis

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These are highlighted grey in my table and include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. Question for the planners: is this is reasonable or sufficient?
3. In the favoured options 2a to 2d, I believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 8774

Received: 29/09/2021

Respondent: Staploe Parish Council

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
4. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
5. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
6. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
d. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.44 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8809

Received: 28/09/2021

Respondent: Mrs Nicola Gooch

1.44 (Draft) Sustainability Appraisal Report – BBC
If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
4. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
5. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
6. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
d. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.44 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8833

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

RESPONSE TO DRAFT SUSTAINABILITY APPRIASAL REPORT

5.1 We raise objection to the contents of the Sustainability Appraisal. The framework for considering sustainability is well established, and we do not raise objection to the general scope of the appraisal. However, it is felt that there is an underlying bias towards urban centric growth, which discounts further growth in the Key Service Centres and smaller sustainable villages.

5.2 The four options in Option 2 are described in the consultation as primarily an urban centric set of options focused on growth in and around the urban area and rail connection points. We would argue this approach is far too simplistic and omits an opportunity to enhance the sustainability of Key Service Centres through the provision of additional services and employment opportunities. It also ignores the potential to build upon the community-led ambitions of the many Neighbourhood Plans that have been prepared in the Borough.

5.3 We note that at paragraph 8.10, the Council comment on the merits of growth around rail hubs and yet ignore to a large extent the value of the bus network with high frequency bus services being a far more flexible and viable option in providing an alternative to the car. The delivery of housing growth along high frequency bus networks, such as that served by the No.50 running between Bedford and Rushden, has the knock on benefit of supporting improvements to services and wider improvements to sustainability across a broader range of settlements.

5.4 An enhanced population along the bus network increases passenger numbers which enables improvements to those existing services to be more viable. By enhancing the network as a whole, you can better serve smaller settlements and improve their sustainability as a consequence.

5.5 We would also highlight that sustainable development needs to plan for the longer term. The private petrol/diesel powered motor vehicle/car is considered to have a harmful effect on the environment, contributing to rising CO2 levels and poor air quality. As a consequence, the language of sustainability talks about “reducing the reliance on the private motor vehicle”. However, as we progress forward in carbon neutral/zero emissions vehicles, this notion will be out of date. The Government has brought forward it’s ban on the sale of new petrol and diesel cars to 2030, with all new cars and vans required to deliver zero emissions from the tailpipe from 2035. The car industry has also reacted with many car manufacturers already committed to being fully electric by 2035. In addition the largest manufacturers, such as Volkswagen Group, have committed to their vehicles being carbon neutral at the point of manufacture.

5.6 With the move towards more environmentally friendly forms of private transport which are driven and supported by the ever-growing energy provision coming from renewable sources, the impact of the private motor vehicle will change, and will be part of a range of sustainable transport options.

5.7 We would also raise objection to the very narrow view that somehow sustainability can only be achieved by one model of growth, with a focus on what is new, being located in only a select few locations; and that somehow everything else is not sustainable, nor could ever be altered to become sustainable. In our view it ignores the wider objective of enhancing the sustainability of existing settlements of all sizes, and fails to support the long-term vitality and viability of those existing settlements and the services and facilities they rely upon.

5.8 It also assumes that travel patterns will continue to grow along the same trajectory, but our collective experiences through the Covid19 pandemic have accelerated the trend of home working, supported by advances in technology. As demonstrated by the pandemic, a large proportion of the economy can continue to function without the need to travel, and to some extent this has opened people up to embracing technology and minimising their need to travel to communicate. All development needs to consider, that going forward, a greater proportion of people will be working from home, or in localised hubs, without the need to travel long distances. That degree of flexibility is already coming in the form of communal work spaces, and hot desking centres. Therefore, the provision of high-speed broadband to all new developments, as well as supporting enhancements to the existing network and local services and facilities, is essential in delivering sustainable growth.

5.9 We would therefore conclude, by arguing that the sustainability credentials of the settlement of Sharnbrook should be assessed independently, and without bias, while opportunities for growth in the settlement should be fully considered in light of its sustainability credentials. It is self-evident that Sharnbrook occupies a sustainable location, served by the A6 and is supported by high frequency public transport links via the No.50 bus service running between Rushden and Bedford. The settlement is independently accessible from the major road network. We believe that the allocation of development at Sharnbrook would meet many of the sustainability objectives the Council are arguing in support of options 2a – 2d, further supporting enhancements to the public transport network serving the village, and as such, would question why further growth here has been discounted.

Object

Representation ID: 8937

Received: 01/10/2021

Respondent: Mr James Browning

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
4. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
5. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
6. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
d. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 9001

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

Growth Strategy Options
2.1 The 2040 Local Plan consultation document sets out the level of housing growth required in
Bedford Borough and the emerging preferred growth strategy options to meet growth needs
within the Plan period. It states that 25,500 homes are required over the 20-year Plan period
from 2020 to 2040, and that as a result of existing commitments totalling 13,000 homes, the
new Local Plan will need to allocate land for a minimum of 12,500 new homes.
2.2 There are four emerging preferred options forming the spatial strategy to meet this growth.
These are:
• Option 2a: Development in and around the urban area, plus A421 transport corridor with
rail-based growth and southern parishes growth.
• Option 2b: Development in and around the urban area, plus A421 transport corridor with
rail-based growth and southern parishes growth, plus one new settlement.
• Option 2c: Development in and around the urban area, plus A421 transport corridor with
rail-based growth, plus two new settlements.
• Option 2d: Development in and around the urban area, plus A421 transport corridor with
rail-based growth, southern and eastern parishes growth, plus one new settlement.
(emphasis added)
2.3 Of the four growth options currently being consulted on, three include the provision of at least
one new settlement. The new settlement options that have been selected at this stage are:
• Little Barford – 3,085 dwellings; and
• Wyboston – 2,500 dwellings.
2.4 The inclusion of one new settlement as part of the growth strategy (options 2b and 2d) would
provide c.20-25% of the housing allocations required over the Plan period. If two new
settlements were included (option 2c), these would provide c.45% of the growth required. This
represents a significant proportion of proposed development across the Borough over the 20-
year plan period.
Growth in Huntingdonshire
2.5 The 2040 Local Plan consultation document shows that both new settlements are located on the
eastern edge of the Borough, in close proximity to the administrative boundary of BBC’s
neighbouring authority Huntingdonshire District Council (HDC). Where new development is
proposed adjacent or near to the boundary with other local authorities, it is important that the
combined effects are taken into account. The location of the new settlements therefore raises
questions around the impact on Huntingdonshire and whether the evidence base has adequately
considered the infrastructure requirements and transport mitigation that may be required to
support these growth strategies, as per the NPPF paragraph 24 and the duty to cooperate.
2.6 At this point, it is important to look at the strategy for development within Huntingdonshire.
The District’s new Local Plan adopted in May 2019 (the HDC Plan) sets out that around 75% of
housing will need to be focused in the spatial planning areas, which are defined as Huntingdon,
St Neots, St Ives and Ramsey. A central part of the Plan strategy is development in ‘Strategic

Expansion Locations’ which offer opportunities that are unprecedented in the District for
sustainable development. One of these locations is the growth of St Neots East.
2.7 Policy SEL 2 details the expansion of St Neots East, which allocates 226ha of land for mixed-use
development including, but not limited to, 3,820 homes (3,265 in the plan period) and 22ha of
employment. Combined with additional allocations for 220 homes within St Neots, this growth
equates to over 17% of the District’s allocated housing requirement. The plan below shows the
cumulation of the two new settlement locations in Bedford and the allocation of St Neots East in
HDC.
Figure 2.1 Location plan of St Neots East, Little Barford and Wyboston new settlements relative to St Neots
Source: Lichfields
2.8 With significant development already proposed in this location, it is particularly important that
the cross-boundary implications of the new settlements at Little Barford and Wyboston are
taken into account. A review of the documents submitted for the HDC Plan shows that the
Council liaised with BBC during the preparation of the Plan, and that BBC stated they were
happy with the relationship between St Neots, development south of the A428 in Bedford
Borough (where Little Barford is located) and green infrastructure corridors traversing the
boundary1. It is also noted that HDC specifically clarified with Central Bedfordshire Council
(CDC) that they had no outstanding concerns regarding the expansion of St Neots East2.
2.9 In this context, the following section discusses the evidence base supporting BBC’s consultation document to see if the cross-boundary implications have been adequately considered, as they were by HDC.
The Evidence Base
Bedford Borough Transport Model Local Plan Assessment Summary Report
2.10 This document has been used to inform the Plan making process and provides a summary of the likely effects of four potential development/spatial scenarios on traffic flows in Bedford Borough. More detail on our review of this report and associated model runs can be found in Section 3.0 of this consultation response. It provides a high-level comparison of the scenarios looking at several key transport metrics and identifies the mitigation measures required for each scenario.
2.11 ‘New settlement-focused growth’ was one of the four spatial scenarios tested in the transport model, which focused on providing growth through the creation of one or more new settlements in the Borough. Figure B.3 of the summary report shows that this scenario is based on the four new settlement proposals put forward as part of the 2020 call for sites. This includes Colworth (2,400 homes), Twinwoods (3,495 homes), Wyboston (2,500 homes) and Little Barford (3,085 homes).
2.12 Notably, the four scenarios tested within the assessment are all discrete, and are not considered in combination with one another. For instance, the transport assessment considers ‘urban-focused growth’, ‘infrastructure-focused growth’ and ‘new settlement-focused growth’ as three separate scenarios, whereas the emerging preferred options are a combination of these. The highway impact of the emerging preferred options is therefore unclear in this regard.
2.13 In terms of the effect on traffic beyond the Borough, one of the key transport metrics analysed is ‘cross-boundary impacts’. This is the forecast of vehicle volume to road capacity, measured at junctions outside of Bedford Borough. While this metric could provide a valuable insight into the impact of the proposed new settlements on traffic outside of the Borough, the outcome is limited for two reasons.
• Firstly, the results for the ‘new settlement-focused growth’ scenario reflect the combination of all four new settlements listed above, and not just the two (Wyboston and Little Barford) that have now emerged as the preferred locations. This extends to the assessment of transport mitigation; the ‘cross-boundary impact’ is forecast to neither improve or worsen with the inclusion of mitigation measures, but this includes the mitigation required to support all four new settlements.
• Secondly, the results are intended to present the forecast scale of change between the four development scenarios, highlighting the relative performance of the scenarios and not the absolute performance. For the ‘cross-boundary impact’ metric, the data analysed the number of nodes (junctions) where the volume-capacity ratio exceeded 85% (the threshold for which congestion becomes apparent) and varied significantly (over 5%) across the four growth scenarios.
2.14 As a result of this two-factor approach, the results do not truly reflect the impact on congestion outside of the Borough.
2.15 We acknowledge that more in-depth transport assessments have been carried out which analyse the Little Barford and Wyboston new settlements both alone and in combination. However, while these do appear to analyse the impact on the highway network outside of the Borough,
they are not explicit in terms of the impact on neighbouring authorities or the cross-boundary mitigation required to support the proposals.
(Draft) Sustainability Appraisal Report
2.16 An essential part of the evidence base, this document sets out the sustainability appraisal framework and sustainability objectives for the emerging 2040 Local Plan. The draft report provides an appraisal of the likely social, economic, and environmental effects of each growth strategy option put forward in the process of Plan preparation and concludes that the four emerging preferred growth options (2a to 2d) are the best performing overall.
2.17 Throughout the appraisal of each spatial option, there is not a clear consideration of the sustainability impacts on neighbouring authorities. The only point that categorically discusses the wider social, economic and environmental impact outside of Bedford relates to the objective to ‘promote vital and viable town centres’; the comments for spatial options including a new settlement state that residents might visit competing town centres outside of the Borough if these are nearer or easier to visit with improved transport links.
2.18 Further, the assessment states that locating growth in new settlements is still likely to increase the need to travel and length of trips to ‘the urban area’, which is where most services, facilities and employment opportunities will remain located. Here, the urban area refers to Bedford only and not nearby settlements beyond the Borough boundary which are geographically closer to the two new settlement proposals.
2.19 The lack of consideration around the potential cross-boundary impacts on Huntingdonshire (or any other neighbouring local authority) within the report may be due to the fact that there is no specific reference to this within the fifteen sustainability appraisal objectives. It appears that this matter has been somewhat neglected, and that the sole focus of the appraisal is on the effects within Bedford. It is therefore questionable whether the sustainability appraisal is sufficiently robust in justifying the preferred growth options; strategic discussions between neighbouring authorities is essential to the delivery of sustainable development (e.g. sustainable transport links).
Development Strategy Topic Paper
2.20 It is a requirement of the Plan-making process that Plans are tested to ensure their deliverability. This document provides a deliverability assessment of the development strategy options that have been considered so far in the preparation of the new Local Plan, in particular why options 2a, 2b, 2c and 2d have emerged as the preferred options for inclusion in the consultation document.
2.21 The deliverability analysis of each option is high level only. This is due to the absence of more detailed work, including a full infrastructure delivery appraisal, Plan wide or site-specific viability appraisals and detailed transport modelling. For each option, the key strengths and weakness are identified as a basis for determining whether, in delivery terms, there is a case for them to be selected as preferred options.
2.22 Throughout the analysis, there are only two parts that touch on wider cross-boundary implications. First, in assessing option 2a, one of the delivery challenges identified is that “substantial development has already taken place on the edge of Bedford. Further outward spread runs the risk of coalescence with nearby settlements”. However, given that option 2a focuses growth around the urban area and southern parishes, this only relates to settlements south of Bedford, such as Wootton, Stewartby and Marston Moretaine. It is of concern that this is thought to be a strategic delivery issue for this growth option, but not for others proposing a
new settlement on the eastern edge of the Borough, given that these pose a greater risk of coalescence with St Neots.
2.23 For options 2a to 2d (the emerging preferred options), a strength is identified as the ‘opportunity to establish a new planned community at Wyboston or Little Barford in proximity to the proposed EWR station at St Neots / Tempsford’. It therefore acknowledges the proximity of the proposed new settlement options to existing areas within Huntingdonshire; however, it does not then consider the cumulative impact of this on the neighbouring local authority as a weakness. This appears to be one-sided, disregarding the cross-boundary impact as a delivery challenge.
2.24 Taking the two points above together, the deliverability analysis is therefore inconsistent in its approach and does not represent an objective assessment of each option.
Issues & Options Consultation – Summary and responses
2.25 This document summarises responses to the 2020 Issues and Options consultation. In the comments received (not specifically attributed to any party), concern was expressed about the impact of growth on communities and infrastructure beyond the Borough boundary (particularly around St Neots), and that cross-boundary discussions should continue through the Duty to Co-operate. Other respondents also felt that the cumulative impact on infrastructure is important and therefore cross-boundary master-planning may be an option. The Council’s response does not provide a clear and reasonable answer to these concerns.
Cooperation with Huntingdonshire
2.26 As set out above, a review of the evidence base supporting the consultation document indicates that the location of the proposed new settlements adjacent to Huntingdonshire has not been adequately assessed. Overall, it does not provide a clear justification demonstrating that there will be no significant adverse impacts on the neighbouring Authority in terms of deliverability, highway mitigation and infrastructure, and further evidence is needed to show that the proposed new settlements are achievable; significant investment in infrastructure may be necessary in order to deliver development in this area at scale.
2.27 National policy states that:
“Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary.” (NPPF Paragraph 26).
2.28 To demonstrate effective and on-going joint working, national policy requires strategic policy-making authorities to prepare and maintain statements of common ground documenting the cross-boundary matters being addressed and progress in cooperating to address these. The statements should be made publicly available throughout the Plan-making process to provide transparency (NPPF, Paragraph 27). They also form part of the evidence required to show that local planning authorities have complied with the Duty to Cooperate; this is a legal duty to engage constructively and actively with neighbouring authorities and other prescribed bodies in planning for strategic matters that cross administrative boundaries.
2.29 A Duty to Cooperate statement forms part of the evidence base for the adopted Bedford Local Plan 2030. While the adopted Plan does not include any proposals for new settlements, those put forward in the 2020 call for sites were consulted on throughout the Plan-making process. In the record of cooperation, one of the issues identified was that a new garden village at Wyboston would be adjacent to Huntingdonshire. The record goes on to state that should the Wyboston
proposal proceed, there will be a need for cross-boundary implications to be assessed by HDC and BBC and that ”the two Councils will continue to cooperate in respect of future new settlement proposals”.
2.30 Following this, we cannot find any evidence that further discussions are taking place with neighbouring authorities now that new settlement proposals in this area are being consulted on. For Plan-making, national planning practice guidance (NPPG) makes clear that councils are expected to document the activities undertaken during the process of addressing strategic cross-boundary matters, including working together at the outset of Plan-making and producing joint research. This is particularly important for new settlements, which typically constitute a significant proportion of growth over the Plan period, and even more so now in the context of the NPPF 2021 paragraph 22 and the need to develop a vision within which to set policies for larger scale development such as new settlements for a minimum of 30 years, ten years more than the emerging Plan period. The proposition for a new settlement at Wyboston is in excess of 10,000 new homes3, quadruple the emerging allocation figure of 2,500 and with a potential impact on Huntingdonshire which is significantly greater than that associated with just 2,500 homes. Little Barford has an emerging allocation for 3,085 homes, with its maximum potential set out as 3,385 to 3,955 in the site pro-forma4, which is more in line with the 2040 Local Plan.
2.31 It is therefore not clear that BBC is currently cooperating with HDC in assessing the cross-boundary impacts of the proposed new settlements at Little Barford and Wyboston. Such an approach is not in compliance with national policy. The Council needs to show that it is engaging with HDC to determine that the new settlements are deliverable over the Plan period and that they are based on effective joint working across the local authority boundaries. This evidence is also needed to provide communities and other stakeholders with a transparent picture of how they have collaborated.

Object

Representation ID: 9061

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

4.1. We bring into question the validity of the methodology and the results of some of BBC’s Draft Sustainability Appraisal. We summarise our points in relation to the Sustainability Appraisal below. Please note, we make extensive representations about the ‘Urban’ component of the Sustainability Appraisal and its Reasonable Alternatives in our ‘Urban and Settlement Capacity section’ – we request that BBC please ensures that those representations are captured in response to the Sustainability Appraisal as well as urban and settlement capacity (including previously developed land) more generally.
• As we state in the Urban and Settlement Capacity section of our representations, it is not reasonable to only show in Option 1a the potential ‘urban capacity’ and ‘adjoining urban areas’ as 1,500 dwellings each giving a total of 3,000 dwellings. As BBC states, these capacity figures are not based on any robust analysis of site availability or development capacity testing therefore this option will need to be revisited once the Council has done a proper capacity study.
• The rejection of Option 1b in the SA has not been justified as the Council cannot conclude that delivering 12,500 dwellings would require ‘extreme densities’ given that the Council has not fully assessed the land available in the urban area.
• If the urban capacity figures were increased to a reasonable level based on sound evidence base, the need to deliver development in less sustainable options such as new settlements or villages would likely not be required.
The SA scores the ‘urban area’ component as ‘negative’ against the air quality objective. It states that “concentrating development of all types in the urban area will mean that remaining areas receive no growth. This will have the effect of concentrating human activity (both long term and short term construction) which is the main cause of poor air quality. Much of the borough will therefore see no worsening of air quality, however the area within the urban area is likely to see worse air quality. This can be minimised with greater use of sustainable transport, which is more likely to occur with concentrated development patterns”16. Apart from being a confusing and contradictory assessment its overall conclusion is poorly considered. Clearly developing in the urban area where facilities and sustainable infrastructure are closest to the population they serve, reduces the need to travel and reinforces important investment in sustainable infrastructure such as Bedford Station and aligns with the Council’s stated Vision and Objectives. We consider this assessment against air quality for this component needs to be revisited.
• We question the SA assessment of ‘new settlements’ component in relation to ‘protect the quantity and quality of water sources’ which scores it as ‘positive’. It states that “locating growth in a few new settlements so that more are unaffected by development is likely to make it easier to protect the quality of water resources”17. We are confused as to the meaning of this statement and how BBC has arrived at such a conclusion.
• It is entirely unclear as to how BBC has merged the 6 development locations into
5. This approach has effectively ensured that the Dennybrook is classified under both point 4 (new settlements) and 5 (rail-based growth).
• Some of the promoted new settlements contain previously developed land whereas Dennybrook does not. We seek clarification as to how this has been taken into consideration in the Sustainability Appraisal as this should be an important factor for the technical assessments undertaken. This point highlights the lack of site specific details contained within the SA about particular sites which leads to the SA amounting to a theoretical exercise in many cases where the important constraints of a site or area have not been taken into account.